The Honorable James Hansen, Chairman
The Honorable Howard Berman, Ranking Member
House Committee on Standards of Official Conduct
HT-2, The Capitol
U. S. House of Representatives
Washington, DC 20515

RE: Ethics Complaint Against Representative Corrine Brown and Call
for Investigation into Possible Violations of Criminal Law and House Rules

Dear Representatives Hansen and Berman:

This letter constitutes a formal ethics complaint against U.S. Representative
Corrine Brown (D-FL), and a request for an inquiry into whether Rep. Brown
received illegal gratuities, bribes or improper gifts, and violated financial
disclosure laws, by accepting an expensive car and lodging from Mr. Foutanga
Dit Babani Sissoko and a $10,000 payment from Rev. Henry Lyons.

This complaint is pursuant to House Rule 10, which authorizes the House
Committee on Standards of Official Conduct ("Ethics Committee") to investigate
"any alleged violation, by a Member, officer, or employee of the House,
of the Code of Official Conduct or of any law, rule, regulation or standard
of conduct applicable to the conduct of such Member, officer, or employee
in the performance of his duties or the discharge of his responsibilities."(1)

On June 3, 1998, the St. Petersburg Times reported that Rep.
Brown repeatedly intervened with the Justice Department and other Members
of Congress on Mr. Sissoko's behalf, and, subsequently, Mr. Sissoko gave
an expensive car to Rep. Brown or her daughter.

A $50,000 luxury car bought by a West African millionaire went to the
daughter of U.S. Rep. Corrine Brown after the lawmaker led a feverish lobbying
campaign to keep the businessman out of federal prison.

Foutanga Dit Babani Sissoko ordered his aides to buy the car for Brown
as a token of his friendship shortly before he went to prison in Miami
for bribery, said one of his attorneys, Tom Spencer.

By the time of the September purchase, the Jacksonville lawmaker had
written two letters to Attorney General Janet Reno, lobbied colleagues
in Congress and met with foreign diplomats on behalf of Sissoko. She later
visited him in prison.

"I was told that it was just a thank you, it was just a gesture of friendship,"
Spencer said of the car....

Brown launched an extensive lobbying effort in Congress [to keep Sissoko
out of jail]. She enlisted colleagues to urge Janet Reno to release Sissoko
under the Immigration and Nationality Act, which allows the attorney general
to deport non-violent criminals before their sentence is completed.

"Corrine was the one who asked me to get involved," recalled Rep. Barney
Frank, D-Mass. "I did not get deeply involved. I just didn't have time."...

[Sissoko lawyer David] Ross said Brown was persistent.

"She went to conservative Republicans as well as liberal Democrats,"
Ross said. "She really pushed. I was with her one time when she called
10 guys in Congress. She buttonholed people and followed them into their
offices."...

Spencer, Sissoko's attorney, said the Lexus was intended as a gift for
the congresswoman. He did not know why it ultimately was given to her daughter.

"If, in fact, it was given to the daughter, it would be a gesture of
thanks to the family for support," Spencer said. "It was apparent to me
that they were very close."...

State records show the car was titled in Shantrel Brown's name last
Sept. 11. Records indicate that someone paid about $50,000 cash for the
car and that Shantrel Brown did not take out a loan for the car. (2)

The St. Petersburg Times also reported that Rep. Brown also accepted
lodging from Mr. Sissoko on Florida's Brickell Key.

Last summer, Brown came to Miami many weekends and stayed at one of
Sissoko's apartments on Brickell Key, Spencer recalled. "Every time I turned
around, I heard she was in town," he said, adding that Shantrel Brown accompanied
her mother on many of those trips.

Rep. Brown repeatedly intervened with the Justice Department to keep Mr.
Sissoko out of prison. She wrote two letters to Attorney General Janet
Reno urging her to deport Mr. Sissoko to West Africa instead of sending
him to prison.(3) In addition, one of these
letters refers to a phone conversation between Attorney General Reno and
Rep. Brown regarding Mr. Sissoko. In that letter, Rep. Brown felt the need
to clarify that, during their phone conversation, she was "not asking for
a personal favor" to keep Mr. Sissoko out of prison.

A: Ethics Committee Should Determine Whether Rep. Brown Violated
the House Gift Rule or the Code of Official Conduct

House Rule 51 prohibits House Members from accepting gifts, with exceptions,
and waivers granted by the Ethics Committee. The rule also prohibits House
Members from allowing family members to accept gifts given because of the
official position of the Member.

A gift to a family member of a Member, officer, or employee, or a gift
to any other individual based on that individual's relationship with the
Member, officer, or employee, shall be considered a gift to the Member,
officer, or employee if it is given with the knowledge and acquiescence
of the Member, officer or employee and the Member, officer, or employee
has reason to believe the gift was given because of the official position
of the Member, officer, or employee.(4)

The gift rule allows some gifts made on the basis of personal friendship,
but forbids House Members from accepting gifts worth more than $250 without
the prior written approval of the Ethics Committee.(5)
In addition, the House Code of Official Conduct states that:

A Member, officer, or employee of the House of Representatives shall
receive no compensation nor shall he permit any compensation to accrue
to his beneficial interest from any source, the receipt of which would
occur by virtue of influence improperly exerted from his position in the
Congress.(6)

We urge the Ethics Committee to investigate whether Rep. Brown has improperly
accepted an expensive car or vacations and personal hospitality which are
impermissible under the gift rule or the Code of Official Conduct.

Federal financial disclosure law requires Members of Congress to publicly
disclose information regarding their holdings, compensation, and financial
transactions, as well as other personal financial details.(7)
Specifically, it requires disclosure of gifts worth more than $250. We
urge the Ethics Committee to review whether Rep. Brown complied with these
financial disclosure requirements.

The St. Petersburg Times account calls into question whether Rep.
Brown and Mr. Sissoko conformed their conduct to the letter of the law.
In particular, Section 201 of the U.S. Criminal Code may have been triggered
by their activities. We strongly urge the Ethics Committee to investigate
whether Rep. Brown has accepted a car and lodging on Brickell Key that
constitute illegal gratuities or bribes.

Federal bribery law states that it is a crime for a federal official
to "directly or indirectly, corruptly" receive or solicit "anything of
value personally or for any other person or entity, in return for...being
influenced in the performance of any official act."(8)
Federal law on illegal gratuities states that it is a crime for a federal
official to directly or indirectly solicit or receive anything of value
other than "as provided by law...for or because of any official act performed
or to be performed."(9)

Although Rep. Brown was not the ultimate decision-maker regarding whether
or not Mr. Sissoko would be kept out of jail, her letter-writing and lobbying
campaigns on behalf of Mr. Sissoko were affirmative "official acts" within
the meaning of the federal bribery statute.

During her campaign for re-election in 1996, U.S. Rep. Corrine Brown
of Jacksonville accepted $ 10,000 from a secret Wisconsin bank account
Baptist leader Henry J. Lyons allegedly used for money laundering.

A longtime political ally of Lyons, Brown did not report the money on
either her financial disclosure statements or her campaign contribution
reports....

[Brown's attorneys said that] She did not use the money for personal
expenses, nor did Lyons get special treatment because of the payment, they
said. The $10,000 was solicited from Lyons, they explained, to help pay
for a rally Brown organized to protest a legal challenge to the shape and
racial makeup of her congressional district....

The money came from a secret account in Milwaukee that is a focus of
the charges against Lyons. Prosecutors allege that Lyons, president of
the National Baptist Convention USA, hid more than $1-million in the account.(10)

We strongly urge the Ethics Committee to determine whether, in receiving
this $10,000 payment, Rep. Brown has accepted an illegal gratuity in violation
of section 201 of the U.S. Criminal Code, accepted an improper gift in
violation of House Rule 51, and failed to disclose the $10,000 payment
as required by federal financial disclosure law.

E: Conclusion

The St. Petersburg Times articles suggest that Rep. Corrine Brown
may have violated criminal laws and House Rules which safeguard the integrity
of Congress. We strongly urge the Ethics Committee to swiftly authorize
an investigative subcommittee to investigate Rep. Brown, and to appoint
an outside counsel to conduct the investigation.

Sincerely,

Gary Ruskin
Director

Certificate of Service

This is to certify that I have today, by hand delivery, provided an
exact copy of this complaint to the Respondent in this matter, Representative
Corrine Brown, at the following address:

Representative Corrine Brown
1610 Longworth House Office Building
U.S. House of Representatives
Washington, DC 20515

Gary Ruskin
Complainant

Endnotes

1. House Rule 10, clause 4(e)(2).

2. Bill Adair and David Dahl, "The Representative,
The Millionaire, and the Luxury Car." St. Petersburg Times, 3 June
1998. Attachment #1 also includes Jim DeFede, "The Baba Chronicles." Miami
New Times, 25 September 1997.

3. Correspondence from Representative Corrine Brown
to Honorable Janet Reno, 11 June 1997 and 17 June 1997. See Attachment
#2.

4. House Rule 51, clause 1(b)(2)(A).

5. House Rule 51, clause 1(e).

6. House Rule 43, clause 3.

7. 5 U.S.C. app. 6, §§101-111.

8. 18 U.S.C. § 201(b)(2)(A).

9. 18 U.S.C. § 201(c)(1)(B).

10. Monica Davey, David Barstow and David Dahl.
"Lawmaker Got $10,000 from Lyons Fund." St. Petersburg Times, April
14, 1998. Attachment #2 also includes "A $10,000 Mystery." St. Petersburg
Times, April 15, 1998.